Justia Criminal Law Opinion Summaries

The defendant was involved in a fatal shooting after following the victim’s vehicle, approaching the victim, and engaging in a verbal confrontation that escalated. The defendant attempted to grab a BB gun from the victim, failed, and then fired four shots with his own firearm, striking and ultimately killing the victim. The defendant claimed he acted in self-defense, asserting he believed the victim was about to use deadly force against him. The evidence included eyewitness testimony and physical evidence regarding the sequence of events and the location of weapons at the scene.The case was initially tried in the Superior Court in the judicial district of New Haven. The jury found the defendant not guilty of murder but guilty of intentional manslaughter in the first degree with a firearm, carrying a pistol or revolver without a permit, and criminal possession of a firearm. The defendant was sentenced to thirty-three years of imprisonment. On appeal, he challenged only his conviction for intentional manslaughter, arguing that (1) the trial court had failed to instruct the jury to unanimously agree on which statutory disqualification to self-defense applied, (2) the jury instructions were misleading regarding the initial aggressor and recklessness-based offenses, and (3) the evidence was insufficient to disprove self-defense or establish intent.The Supreme Court of Connecticut reviewed the appeal. It held that, consistent with its reasoning in State v. Mekoshvili, the federal constitution does not require jurors to unanimously agree on which specific statutory disqualification to self-defense was established, so long as they unanimously reject self-defense. The Court also found no merit in the defendant’s claims of instructional error or insufficiency of evidence. The judgment of the Superior Court was affirmed. View "State v. Matheney" on Justia Law

The case concerns an individual convicted of felony murder, first-degree robbery, and conspiracy to commit first-degree robbery related to a shooting death during a transaction arranged via Craigslist. Key facts established that the victim met with the accused and another man, Marvin Mathis, to sell electronic tablets. The victim was shot and died, and evidence tied the accused and Mathis to the scene through phone records, witness statements, and the accused’s own admissions. A third individual, Thompson, also described a plan to rob the victim.After conviction, Mathis was separately tried and found not guilty by reason of mental disease or defect under Connecticut law, with the court finding he lacked capacity to appreciate the wrongfulness of his conduct or conform it to legal requirements. The petitioner then filed for habeas corpus, arguing that Mathis’ acquittal constituted newly discovered evidence of the petitioner’s actual innocence, since a conspiracy requires the intent of at least two parties.The Superior Court denied the habeas petition, holding that Mathis’ acquittal was irrelevant to the petitioner’s innocence. The Appellate Court disagreed with the legal analysis, holding that evidence from Mathis’ trial should be considered, but still affirmed the denial, finding that a conspiracy could have existed between the petitioner and Thompson.On further appeal, the Connecticut Supreme Court held that while the Appellate Court applied the correct standard by considering aggregate evidence, it erred in concluding that Mathis’ acquittal clearly proved he could not have intended to conspire. The Supreme Court explained that an insanity acquittal does not necessarily negate specific intent, as the underlying findings were made by a preponderance of the evidence, not clear and convincing evidence. Thus, the Court affirmed the judgment, concluding the petitioner had not met the burden to prove actual innocence. View "Moon v. Commissioner of Correction" on Justia Law

In this case, the defendant was charged with murder, burglary in the first degree, conspiracy to commit burglary in the first degree, and tampering with physical evidence, arising from the killing of a woman with whom he had an intimate relationship. The prosecution alleged that, following the discovery of the victim’s decomposed body, police conducted three interviews with the defendant. After waiving his Miranda rights in the second interview, he made incriminating statements and then said he was “done talking.” The next morning, while awaiting arraignment, the defendant initiated a third interview, again waived Miranda rights, and admitted to the killing.The trial took place in the Superior Court, judicial district of Waterbury, where a jury found the defendant guilty of all charges except conspiracy to commit tampering with physical evidence, which the court vacated at sentencing. The defense moved to suppress statements from the third interview, arguing the police had failed to clarify the defendant’s equivocal request for counsel under Connecticut law, and to suppress cell phone records as unsupported by probable cause and lacking particularity. The court denied these motions.On direct appeal, the Connecticut Supreme Court reviewed the trial court’s rulings. The Supreme Court held that any Miranda-based challenge to the admission of the second interview was waived by defense counsel, who had limited objections to the third interview only. Regarding the third interview, the Court found that rereading Miranda warnings and obtaining a written waiver sufficiently clarified the defendant’s equivocal request for counsel, satisfying State v. Purcell. The Court also determined the warrant for cell phone records was supported by probable cause and was sufficiently particular. The judgment of the Superior Court was affirmed. View "State v. Johnson" on Justia Law

The petitioner was convicted of conspiracy to commit robbery in the first degree, attempt to commit robbery in the first degree, and assault in the first degree, arising from the shooting of a pizza delivery driver. The prosecution’s case relied heavily on the testimony of an individual who was present with the petitioner on the night of the incident. This individual testified that the petitioner had used his cell phone to call and "case" various businesses, including the pizza restaurant employing the victim, to identify potential robbery targets. The defense argued that this individual was actually the perpetrator, not the petitioner.After conviction, the petitioner filed for a writ of habeas corpus in the Superior Court for the judicial district of Tolland, alleging ineffective assistance of counsel due to his trial attorney’s failure to investigate the key witness’s cell phone records and failure to interview additional potential alibi witnesses. The habeas court denied the petition. On appeal, the Appellate Court agreed that trial counsel’s performance was deficient for not investigating the cell phone records but determined, by a majority, that the petitioner had not shown sufficient prejudice resulting from this deficiency. The Appellate Court affirmed the habeas court’s judgment.Upon further appeal, the Supreme Court of Connecticut reviewed whether the petitioner was prejudiced by trial counsel’s failure to investigate the cell phone records. The Supreme Court held that there was a reasonable probability that, had the records been investigated and introduced at trial, the jury would have had reasonable doubt about the petitioner’s guilt. The cell phone records would have undermined the credibility of the key witness’s account and a corroborating police officer’s testimony, and supported the defense theory of third-party culpability. The Supreme Court reversed the Appellate Court’s judgment, directed that the habeas petition be granted, the convictions vacated, and a new trial ordered. View "Grant v. Commissioner of Correction" on Justia Law

The defendant was charged with multiple counts of sexual assault in the first degree and risk of injury to a child, stemming from multiple incidents of sexual abuse against two minor victims who attended an in-home day care operated by the defendant’s wife in New Haven. The alleged abuse occurred between 2007 and 2012, when the victims were approximately three to eight years old. Each count of sexual assault was predicated on multiple, separate instances of specific sexual acts committed by the defendant. Following police investigations in 2019 and subsequent arrest in 2020, the defendant was tried on these charges.At trial in the Superior Court for the judicial district of New Haven, the prosecution presented evidence of several distinct incidents of sexual abuse. The trial judge provided the jury with a specific unanimity instruction for each count, requiring jurors to unanimously agree that the defendant committed at least one specific instance of the charged conduct in order to find him guilty on any particular count. The jury found the defendant guilty on all counts of sexual assault and risk of injury to a child, and the court sentenced him to a total effective sentence of twenty-five years, with execution suspended after twenty-one years and ten years of probation.On direct appeal to the Connecticut Supreme Court, the defendant argued that his federal constitutional right to a unanimous jury verdict was violated because the trial court did not require the jury to answer special interrogatories regarding unanimity on each alleged incident, despite providing proper unanimity instructions. The Connecticut Supreme Court held that the constitution does not require special interrogatories in addition to specific unanimity instructions for counts charging multiple instances of conduct. The court affirmed the judgments of conviction. View "State v. Carlos G." on Justia Law

On the evening of November 10, 2021, the defendant unlawfully entered a residence in West Hartford, Connecticut, where multiple individuals were present, including his ex-girlfriend and her family. The defendant shot one of the occupants, Dyquan Daniels, in the face and threatened another before fleeing. Police apprehended the defendant shortly afterward and found gunshot residue on his hand. The prosecution charged the defendant with several offenses, including home invasion, assault in the first degree by discharge of a firearm, criminal possession of a firearm, threatening in the second degree, and two counts of risk of injury to a child.The case was tried before the Superior Court in the judicial district of Hartford. The state’s operative information charged the defendant generally under the home invasion statute, with language tracking one specific subdivision, but did not specify a particular subsection or subdivision. During trial, defense counsel argued a third-party culpability defense, suggesting someone else committed the shooting. The trial court instructed the jury on home invasion using a different subdivision than the one tracked in the information, requiring proof that the defendant was armed with a deadly weapon. The jury found the defendant guilty on all counts.The Connecticut Supreme Court reviewed the appeal. It held that the trial court did not commit plain error in its instructions because the defendant received adequate notice that he could be convicted under either subdivision of the home invasion statute, as the facts alleged and the related counts necessarily involved being armed with a deadly weapon. The court also found no double jeopardy violation, determining that home invasion and assault in the first degree each require proof of distinct elements. The judgment of conviction was affirmed. View "State v. Christon" on Justia Law

The defendant was charged with criminal possession of a firearm or ammunition and criminal violation of a protective order. These charges stemmed from two prior cases involving allegations of sexual assault in the fourth degree and risk of injury to a child, both concerning a minor family member. In each prior case, the Superior Court issued protective orders requiring the defendant to surrender firearms and ammunition. In 2022, the defendant was arrested for allegedly possessing firearms or ammunition in violation of those protective orders.After the 2022 arrest, the defendant moved to dismiss the new charges, arguing that the protective orders were not issued "in a case involving the use, attempted use or threatened use of physical force" as required by Connecticut General Statutes § 53a-217(a)(4)(A), since the underlying offenses did not explicitly include use of physical force as an element. The Superior Court denied the motion to dismiss. The defendant then entered a conditional plea of nolo contendere to one count each of criminal possession of a firearm or ammunition and criminal violation of a protective order. The state entered a nolle prosequi as to the remaining charges. The defendant appealed, and the case was transferred from the Appellate Court to the Connecticut Supreme Court.The Connecticut Supreme Court affirmed the judgment. It held that the phrase "a case involving" in § 53a-217(a)(4)(A) is broadly inclusive and refers to the overall proceeding, not just the elements of the charged offense. Therefore, protective orders issued during prosecutions for sex offenses, where the use or threat of physical force or superior physical strength was present in any aspect, satisfy the statute. The court also rejected the defendant’s claim that the statute was unconstitutionally vague as applied, finding it provided sufficient guidance. Finally, the court determined that the defendant’s Second Amendment challenge to the validity of the protective orders was barred by the collateral bar rule. View "State v. Enrrique H." on Justia Law

The defendant was involved in a fatal shooting during a drug transaction in Hartford, Connecticut. He testified at trial that he acted in self-defense, claiming the victim drew a gun on him during a dispute. However, other witnesses contradicted this account, and no gun was found on or near the victim. After the shooting, the defendant fled the scene and did not report the incident to the police. He was later arrested and charged with murder.The case was tried before the Superior Court in the judicial district of Hartford. At trial, the defendant testified in his own defense. The prosecutor, with approval from the trial court, cross-examined the defendant regarding his failure to report to police that he had acted in self-defense prior to his arrest. The defense objected, arguing that the questioning infringed upon the defendant’s right to remain silent, but the trial court overruled the objection, reasoning that, by testifying, the defendant waived his Fifth Amendment right regarding silence and that his failure to report was inconsistent with a claim of self-defense. The jury found the defendant guilty of murder, and he was sentenced to fifty years in prison.On direct appeal to the Supreme Court of Connecticut, the defendant argued that the trial court committed plain error by allowing the prosecutor to cross-examine him about his prearrest silence. The Supreme Court of Connecticut held that the trial court did not commit plain error because established case law allows impeachment using a defendant’s prearrest, pre-Miranda silence, particularly when the defendant testifies and claims self-defense. The Court concluded that the circumstances did not present an obvious or egregious error requiring reversal. The judgment of conviction was affirmed. View "State v. Thorpe" on Justia Law

The case involved a defendant who, while driving a sport utility vehicle (SUV) without a license, struck and fatally injured a pedestrian at an intersection in Waterbury, Connecticut. The defendant fled the scene without stopping. Several miles away, after the SUV broke down and partially blocked a residential driveway, the defendant, with the help of the homeowner and a taxi driver, pushed the damaged SUV into the driveway, leaving it at the front of other vehicles with its damaged front end fully visible from the street. The defendant did not attempt to hide the SUV further, nor did he inform the homeowner of the accident.A jury in the Superior Court for the judicial district of Waterbury found the defendant guilty of evasion of responsibility in the operation of a motor vehicle and tampering with physical evidence, based on the state’s theory that the defendant concealed the SUV to impair its availability in a criminal investigation. The Appellate Court affirmed the convictions, holding that a rational juror could find the act of concealment based on the context and circumstances, including the defendant’s flight from the scene and the temporary abandonment of the SUV in a private driveway.On further review, the Supreme Court of Connecticut concluded that the evidence was insufficient to establish concealment under General Statutes § 53a-155 (a). The court held that simply leaving the SUV in a visible spot at the front of a driveway, where its damage was apparent from the street, did not constitute concealment as required by the statute. The Supreme Court reversed the tampering conviction, directing the trial court to enter a judgment of acquittal on that charge and leaving resentencing, if any, to the trial court’s discretion. The remaining conviction was affirmed. View "State v. Bolden" on Justia Law

The case involved a fatal shooting that followed a car accident in Hartford, Connecticut. The defendant, after colliding with the victim’s vehicle, agreed to pay for the damages and arranged to meet the victim later that day. Surveillance footage and eyewitness accounts linked the defendant to the scene, describing his distinctive clothing and actions. Evidence showed the defendant met with the victim, shot him multiple times, and fled the scene. Forensic analysis detected gunshot residue on the defendant’s clothing, and cellphone data further corroborated his involvement. The defendant was subsequently arrested and charged with murder and criminal possession of a firearm.At trial in the Superior Court for the judicial district of Hartford, the jury found the defendant guilty of murder, and the court found him guilty of criminal possession of a firearm. The defendant appealed directly to the Connecticut Supreme Court, raising several unpreserved constitutional claims. He argued that his right to confrontation was violated when the State’s gunshot residue expert testified based on data and notes from a nontestifying analyst, and when the prosecutor elicited testimonial hearsay on cross-examination. He also alleged prosecutorial impropriety for introducing facts not in evidence during cross-examination.The Connecticut Supreme Court held that the claim regarding the expert’s reliance on the nontestifying analyst’s materials failed because the record was inadequate to determine whether those materials were testimonial. The court declined to adopt the State’s proposed rule barring all unpreserved confrontation claims and reaffirmed that such claims may still be reviewed if the record is sufficient. The court further held there was no confrontation clause violation or prosecutorial impropriety regarding the cross-examination, as the questions did not introduce hearsay or inadmissible evidence. The judgment of conviction was affirmed. View "State of Connecticut v. Bester" on Justia Law